Natural and Culturo-Historical Region of Kotor

• Lack of Management System/Management Plan
• Inadequate legal framework
• Building and development (accelerated urban development and urban pressure)
• Ground transportation infrastructure (proposed major bridge at Verige and other proposed development projects)
• Major visitor accommodation and associated infrastructure
• Land conversion
• Society’s valuing of heritage
• Changes in traditional ways of life and knowledge system
• Impacts of tourism/visitor/recreation
• Earthquake damage (issue resolved)
• Lack of buffer zone (issue resolved)

N/A

On 1 February 2024, the State Party submitted a state of conservation report, which is available at https://whc.unesco.org/en/list/125/documents/ and presents the following progress:

• The State Party has invested in the development of legal procedures and expertise to meet international standards, such as the integration of Heritage Impact Assessments (HIAs) into its legislative and administrative system, following the adoption of the Law on the Protection of the Natural and Cultural-Historical Region of Kotor in December 2019. However, the Administration for the Protection of Cultural Heritage faces challenges due to the lack of qualified staff and the additional pressure on the administration resulting from the strict legal requirements for the implementation of HIAs;
• The draft Management Plan, requested by the 2018 Reactive Monitoring Mission is in the final stages of preparation before being transmitted to the World Heritage Centre for comments and then sent to the government for approval. It will incorporate the conclusions and recommendations of the National Disaster Risk Assessment, adopted in December 2021;
• The vision for the spatial development of the Municipality of Kotor is linked to the sustainable development of tourism, and aims at finding a balance between tourism, the protection of the property’s Outstanding Universal Value (OUV) and the everyday life of the citizens. To this end, the Municipality of Kotor has adopted the ‘Tourism Development Strategy of Kotor until 2030’, which envisages a series of measures to reduce the daily tourist pressure, is preparing a ‘Sustainability Study of Tourism in Kotor’, and, together with the Port of Kotor, has established cooperation with representatives of the Global Sustainable Tourism Council (GSTC) and the Cruise Lines International Association (CLIA) to develop guidelines for improving destination sustainability;
• The Spatial Urban Plan of Tivat is currently in force for the Lepetani area and a lower-order planning document will be prepared to re-evaluate the area;
• The buffer zone study, which defines areas in and around the property where an impact assessment should be required for potential projects, is a priority and is in its final conceptualisation stage;
• An alternative location for the Verige bridge was considered in the Study of the Protection of Cultural Properties, prepared for the Montenegro Coastal Development Plan. Subsequently, the Ministry of Culture has proposed to carry out an HIA that will include a comparative analysis of at least three solutions: the Verige bridge, the Lustica Zelenka bridge and an underwater tunnel. The aim is to identify the most appropriate solution, if any, to facilitate traffic in the coastal area, taking into account the landscape and the site’s morphological complexities;
• Plans for the Morinj accommodation complex have been abandoned and the detailed spatial plan for the construction of a hotel complex on the former Fjord Hotel site and the Jugooceanija building is being translated prior to submission to the World Heritage Centre;
• HIAs have been prepared for a significant number of other proposed developments: residential developments in Strp, in Dobrota, Morinj and Orahovac; the Bokej football stadium; and tourist developments in Risan. Separate HIAs for the three quarries in the buffer zone were simultaneously submitted to the World Heritage Centre on 31 January 2024. Their approval has been withheld pending receipt of the ICOMOS Technical Review, after which the Ministry of Culture and Media will take appropriate action.

The continued integration of HIA processes into the legislative and administrative system through the implementation of the Law on the Protection of the Natural and Cultural-Historical Region of Kotor is welcomed. However, it remains a concern that there is a lack of qualified expertise and that the buffer zone study to define areas in and around the property has not yet been completed, putting unmanageable pressure on the Administration for the Protection of Cultural Property. The State Party is strongly encouraged to continue to invest in the further development of expertise and in capacity building activities in the field of cultural heritage and impact assessment, and to complete the buffer zone study without delay and submit it to the World Heritage Centre for review by the Advisory Bodies.

While acknowledging the complexity of revising the Management Plan for the property and the State Party’s work over the past years, it remains a concern that this has not yet been completed since the 2018 mission. The incorporation of the recommendations of the National Disaster Risk Assessment of December 2021 and the intangible values of the property into the Management Plan is welcomed. The State Party is therefore requested to give priority to this revision to make the Management Plan a fully operational tool for the effective management of the entire World Heritage property and its buffer zone, and to submit the final draft to the World Heritage Centre for review by the Advisory Bodies prior to its formal adoption.

In the meantime, the State Party is also invited to address the issues of development in accordance with the Spatial Urban Plan for Kotor, disaster risk reduction and tourism management, including issues related to the direct, indirect and cumulative impacts that tourism may have on the property. It is noted that all development projects in the Municipality of Kotor are in line with the Spatial Urban Plan of Kotor, which was adopted in 2020 as an integral part of the Spatial Plan and incorporates all relevant recommendations of the 2018 mission, that HIAs are undertaken for all projects that may have a potential impact on the property’s OUV, and that several modalities are proposed to strengthen the control over the implementation of the Spatial Urban Plan while the Management Plan is being completed. However, it is also noted that the moratorium on new construction imposed until the adoption of the Spatial Urban Plan for Kotor and the revision of the Management Plan expired in 2020, without the Management Plan having been finalised, and that numerous development projects are being planned and developed without taking into consideration their potential cumulative impacts. This also underlines the utmost urgency of completing the Management Plan and the fact that it addresses the issue of a proactive and strategic approach to landscape level planning, which will help to manage the workload and pressure of conducting impact assessments.

The State Party’s efforts to find an adequate management model for the property that will ensure the preservation of the OUV of the property and the normal daily life and functioning of its citizens, as well as the sustainable development of tourism, are noted. The adoption of the ‘Tourism Development Strategy of Kotor until 2030’, which provides for a series of measures to reduce the daily tourist pressure, the preparation of a ‘Sustainability Study of Tourism in Kotor’, as well as the cooperation established between the Municipality of Kotor, the Port of Kotor and industry representatives to improve destination sustainability are noted. As both the World Heritage status and the property’s OUV constitute an important basis for tourism, the State Party is invited to give priority consideration to the protection of the OUV of the property in the development of tourism strategies and to submit any relevant strategic document to the World Heritage Centre for review by the Advisory Bodies prior to its finalisation and implementation.

The updated information received on the various documents requested by the Committee in its Decision 45 COM 7B.191 is welcomed. Although the Spatial Urban Plan of Tivat is currently in force for the Lepetani area, it is of concern that it does not provide direct building requirements and that the Municipality plans to re-evaluate this area through another planning document, although this process does not appear to have started yet. The State Party is invited to promptly prepare this, as well as the detailed spatial plan for the conversion and construction of a hotel complex on the site of the former Fjord Hotel and the Jugooceanija building without delay and to submit all documents to the World Heritage Centre for review by the Advisory Bodies.

It is welcomed that the State Party is considering alternative solutions for the Verige bridge and for addressing the problem of traffic and transport in a way that takes into account the lives of citizens and the OUV of the property. The World Heritage Centre and the Advisory Bodies stand ready to advise the State Party in its efforts to involve appropriate expertise. The outcome of this process should be transmitted to the World Heritage Centre for review by the Advisory Bodies.

The World Heritage Centre has received a significant number of HIAs. The recommendations of the relevant Technical Reviews should be considered by the State Party and integrated into decision-making as they become available. These highlight the pressures that the State Party faces in various areas of development and it is recommended that it considers carrying out Strategic Environmental Assessments (SEA) on issues such as tourism development, transport infrastructure and residential development. This would provide a clear framework for proponents and decision-makers to refer to before investing in the development of proposals and would also have the benefit of more effectively addressing cumulative impacts on the property’s OUV.

With particular reference to the HIAs submitted for the quarries, the ICOMOS Technical Review concluded that the scale and intensity of the proposed quarrying does not appear to be compatible with the sustainable management of the property. It is therefore recommended that no new quarrying concessions be granted and that a mitigation strategy be developed now to limit the potential harm to the property’s OUV.

In view of the large number of development proposals that the State Party has to consider since the lifting of the construction moratorium, which pose a significant risk of cumulative impacts, it may be beneficial for the State Party to invite an Advisory mission to assist in developing a clear and coherent approach to the sustainable management of the property, using all available planning tools, including the management plan and strategic environmental assessment.